§ 1.1361-4T - Effect of QSub election (temporary).

(a)(1) through (a)(8)(ii) [Reserved] For further guidance, see §1.1361-4(a)(1) through (a)(8)(ii).

(iii) Rule for Chapter 49 tax liabilities—(A) In general. A qualified subchapter S subsidiary (QSub) is treated as a separate corporation for purposes of—

(1) Federal tax liabilities imposed by Chapter 49 of the Internal Revenue Code;

(2) Collection of tax imposed by Chapter 49 of the Internal Revenue Code; and

(3) Claims of a credit or refund related to the tax imposed by Chapter 49 of the Internal Revenue Code.

(B) Effective/applicability date for Chapter 49 liabilities. Paragraph (a)(8)(iii)(A) of this section applies to taxes imposed on amounts paid on or after July 1, 2012.

(C) Expiration date. The applicability of paragraph (a)(8)(iii) of this section expires on June 22, 2015 or such earlier date as may be determined under amendments to the regulations issued after June 22, 2012.

(a)(9) through (d) [Reserved] For further guidance, see §1.1361-4(a)(9) through (d).

[T.D. 9596, 77 FR 37806, June 25, 2012]